The retirement of a large number of coal-fired electric generating units (EGUs);

Likely changes in Federal environmental policies; and

Market rules that do not properly value baseload coal-fired generation.

As our letters state, a large number of coal-fired electric EGUs are shutting down because of regulatory policies and low natural gas prices. One-third of the U.S. coal fleet — almost 99,000 MW — has either retired or announced plans to retire. We are concerned that such a large number of retirements raises questions about the ability to maintain a diverse and reliable supply of baseload power. Coal-fired generation is a vital source of affordable electricity and is critical to maintaining the reliability of the electric grid. In both letters we urge these grid operators to consider steps that would avoid further coal-fired EGU retirements.

With the result of the election in November, ACCCE believes the new Administration will withdraw or rewrite environmental regulations that are causing, or could cause, more coal retirements. Therefore, we suggested MISO and PJM take into account the likelihood of changes to Federal environmental policies in their future policy decisions.

Finally, ACCCE believes coal-fired baseload generation is being disadvantaged by unfair subsidies and preferences for other resources. We respectfully requested MISO and PJM re-evaluate their policies in order to ensure the reliability attributes of coal-fired generation are properly valued relative to other less reliable sources of generating capacity.

Given the critical role MISO and PJM have in ensuring reliable operations, efficient wholesale markets, and infrastructure planning for the electric grid, we look forward to being a resource to them and others around the industry on these important topics as ACCCE becomes more engaged in discussions of electricity market reforms.

Recently, we wrote a blog showing how PJM relied on its coal fleet during the so-called Bomb Cyclone. Since we wrote the PJM blog, we’ve reviewed similar data from MISO (PDF). These two RTO/ISOs collectively include 127,000 megawatts (MW) of coal-fueled generating capacity, roughly half the nation...